Digital Product Passport for luxury goods
No passport act of their own, but apparel, leather goods, watches and jewellery are already caught by the ESPR work and the minerals rules. Deadlines, required data, official sources and answers - the reference work on the DPP for luxury goods.
No passport act, and the industry that needs one most
Luxury goods sit in an unusual place in European product law.
Where the law stands
There is no passport act for watches, for jewellery or for leather goods, and none of them appears as a product group in the Commission’s first ecodesign working plan of 16 April 2025. Apparel does, with an indicative delegated act in 2027; footwear was judged less impactful than the priority groups and got a study instead, due to conclude at the end of 2027.
So if you are waiting for the date on which luxury becomes regulated, there is no such date to wait for.
What already binds you
That does not mean nothing binds you. Since 1 January 2021, Union importers of tin, tantalum, tungsten and gold above the volume thresholds of Regulation (EU) 2017/821 have owed a documented due-diligence chain, which reaches every watch case and every gold setting.
Since 19 July 2026, large companies may no longer destroy unsold apparel, clothing accessories and footwear, and from 19 July 2030 the same applies to medium-sized ones. Precious-metal fineness marks remain national, so a piece sold in four markets still meets four hallmarking regimes.
What is actually driving passports here
What is actually driving passports in this industry is not the legislature. It is counterfeiting, and it is resale.
A counterfeit is cheap to make and expensive to disprove; a pre-owned object without a verifiable history loses a large part of its value at the second sale.
Both problems have the same shape - a claim about an object that nobody can check. A signed, item-level record is the smallest thing that fixes it, and it happens to be the same record a delegated act will ask for later.
What this page covers
This page is the reference work for that: the dates that are real, the ones that are only expected, the roles and what each owes, the data an item passport carries, the official sources, and the questions we are asked most often in this industry.
What a passport brings you now
Authentication becomes a scan instead of a service request: a buyer, a boutique or a resale platform checks the signature in the browser and sees that the object’s record came from you.
A signed, item-level record turns three costs into advantages.
Resale keeps its value because the history - the service, the re-certification, the change of hands - travels with the object as versions of one passport. And the object keeps talking to its owner after the sale: care, the workshop’s story, the invitation to register the piece, in the owner’s language, on a page with your branding and no one else’s.
The three biggest hurdles in practice
- Item level, not model level. A model passport is cheap and useless here. Everything that gives a passport its value in luxury - the serial number, the manufacturing date, the service history, the authentication on resale - lives on the individual object. If the data model starts at the reference, it has to be rebuilt.
- The chain is longer than the contract. Origin data for gold, stones and hides sits two or three tiers upstream, with suppliers who have no contractual relationship with you. That data arrives through purchasing terms, not through requests, and purchasing terms take months.
- The object outlives everything around it. A watch is resold decades after the boutique that sold it closed. A passport that goes dark when a contract ends is worse than no passport, because the buyer now reads a broken link as a warning sign.
More on this: signatures and certificates in the DPP and from compliance document to marketing tool.
Timeline for Luxury Goods
Every date the regulation sets for Luxury Goods, in order, from the day it entered into force to the duties of the next decade. Dates that hang on acts the Commission has not adopted yet are marked as such.
- 1 January 2021Conflict-minerals due diligence applies
Union importers of tin, tantalum, tungsten and gold above the volume thresholds of Annex I have to run a management system, assess risks, have the chain audited by a third party and report publicly (Regulation (EU) 2017/821, obligations applicable since 1 January 2021). Gold is the one that reaches watch cases and jewellery.
- 16 April 2025The ESPR working plan names its priorities
The Commission adopts the first ecodesign and energy labelling working plan (COM(2025) 187 final). Textiles, with the focus on apparel, is the first non-energy product group. Furniture, tyres, mattresses, iron and steel and aluminium follow. Footwear is not among them.
- 19 July 2026Destroying unsold apparel and footwear becomes unlawful
Large companies may no longer destroy unsold consumer apparel, clothing accessories and footwear listed in Annex VII of the ESPR (Art. 25). Medium-sized companies follow on 19 July 2030; micro and small companies are exempt. The related duty to disclose what was discarded sits in Article 24.
- 20 July 2026EU DPP register goes live
The central register of the ESPR starts operating, with Implementing Regulation (EU) 2026/1778 setting out how it works, together with a test environment. It is the register every future passport in this industry will be registered in, whichever act eventually mandates one.
- Expected 2027Delegated act on textiles and apparel
The working plan puts the textiles act in 2027 as an indicative year. The passport for apparel, and the requirements behind it, arrive with that act. It has not been adopted, so no date binds an apparel maker yet - only the direction is fixed.
- Expected end of 2027The footwear study concludes
The Commission judged footwear to have lower impacts than the priority groups and commissioned a study instead of an act, to conclude by the end of 2027. Requirements for shoes therefore cannot realistically arrive before 2030.
- 19 July 2030The destruction ban reaches medium-sized companies
What has applied to large companies since 2026 applies to medium-sized ones from this day (Art. 25). The disclosure duty of Article 24 follows the same step.
- Not yet fixedWatches, jewellery and leather goods
None of these is a product group in the first working plan, and none has a passport act of its own. A mid-term review of the working plan is planned for 2028 and can add product groups. Until then, any passport in these categories is a commercial decision, not a legal one.
Who is affected?
Which duties fall on each economic operator along the way to the market.
Maison or manufacturer
Whoever makes the object, or has it made under their own name or mark, holds the record - materials, origin, the workshop, the conformity claims. Where an ESPR act arrives, this is the party that creates and keeps the passport.
Importer
Whoever brings goods into the EU places them on the market and answers for what accompanies them. For gold, tin, tantalum and tungsten above the Annex I thresholds, the importer is also the party that owes the due-diligence record under Regulation (EU) 2017/821, not the supplier abroad.
Distributor and boutique
Checks that what it sells carries the markings, the accompanying information and, where required, a reachable passport. Holds no passport data of its own, but is the point where a missing or unreachable passport turns into a refused sale.
Resale, auction and after-sales
The secondary market is where a passport earns most of its value and where it is most often broken. A repair, a re-certification or a resale should extend the record rather than start a new one, so that the object’s history stays one chain instead of several.
What goes in the DPP for Luxury Goods?
The key data fields required by the relevant EU regulation.
Identity of the individual object
Serial or item identifier, model, reference, date and place of manufacture. Everything else on this list hangs on this field, and it is the field a model-level passport cannot give you.
Material origin
Metals, stones, leather and textile fibres with their origin, plus the due-diligence record that Regulation (EU) 2017/821 requires of Union importers of tin, tantalum, tungsten and gold. Fineness marks for precious metals still follow the national hallmarking rules of each market, not an EU rule.
Craft, care and repair
Manufacturing technique, the workshop, care instructions, service intervals, available spare parts and where to have work done. These are the fields that make an owner open the passport a second time, years after the purchase.
Second life and disposal
Repair and service history, authentication events on resale, and, for large companies in apparel and footwear, the record behind the disclosure of unsold goods discarded per year (Art. 24 ESPR).
Checklist for Luxury Goods
The EU has not yet published which data points a product passport for Luxury Goods has to carry: the act that fixes them is pending. As soon as it is public, a checklist for Luxury Goods appears here, as a page and as a PDF, the way the battery checklists follow the regulation text today. Until then, the required data above and the official documents below are the reliable guide.
Transpareo for Luxury Goods
No act obliges luxury to carry a passport, which is why the case rests on what it earns: fewer counterfeits, a resale market that keeps value, and a relationship with the owner that outlasts the boutique. Transpareo gives you an item-level passport with the fields this industry actually needs - identity, materials and origin, craft and care, service and ownership history - and lets you decide field by field who may read what. Every publication is signed and every earlier version stays retrievable, so a resale platform can verify years later that the record came from you, and the passport stays reachable through a permanent address for as long as the object exists. Every duty named above has its counterpart below.
Every duty has its counterpart
One passport per object
Item-level passports with serial identifiers, not one record stretched over a reference. With a GTIN the identifier becomes a GS1 Digital Link; without one, a unique Transpareo identifier, and Transpareo produces the QR code for the guarantee card, the label or the engraving.
Signed, and provable later
Every publication is a signed version and earlier versions stay retrievable. A resale platform can check that the record it is reading was issued by you, years after the sale, without calling your customer service.
Public, client and authority tiers
Visibility is a property of every data field. Materials and care instructions can be public, service history and ownership records restricted through logged access, and supplier documentation reserved for authorities - all in one passport, behind one code.
The record grows with the object
A repair, a re-certification, a change of owner adds a version rather than a new passport. The chain stays one chain, which is exactly what the secondary market is missing today.
The object keeps talking after the sale
The passport page is a landing page with your branding - care instructions, the workshop’s story, an invitation to register the piece or book a service. Every scan is a contact with an owner, not a visit to a marketplace. Materials, origin documents and workshop records arrive through the interface, by Excel import or the REST API, with a source note per property.
24 EU languages and 16 more
Care instructions, provenance text and craft descriptions appear in the language of every market, translated automatically and checked by you before publication.
Frequently asked questions about the DPP for Luxury Goods
Is there a DPP obligation for luxury goods today?
No, and it is worth saying plainly. There is no passport act for watches, jewellery or leather goods, and none is in the first ecodesign working plan. Apparel is the closest thing to a fixed direction - the textiles delegated act carries an indicative year of 2027 in the working plan, and the passport requirements arrive with it. What already binds you today are the minerals rules of Regulation (EU) 2017/821 and, since 19 July 2026, the ban on destroying unsold apparel and footwear. What makes a passport worthwhile without any act is what it does for the object - authentication in a scan, a history that keeps resale value, and a page that keeps the owner in touch with you.
Which of my product lines are already in scope?
Ready-to-wear falls under the textiles work, so a delegated act will reach it. Footwear does not - the Commission judged its impacts lower than the priority groups and commissioned a study instead, due to conclude at the end of 2027. Handbags, watches and jewellery are in no product group at all. If you sell across all four, you will be preparing one passport structure and switching categories on at different times, which is an argument for building it once rather than per line.
Does this apply to importers too?
For the minerals rules, the importer is the addressee - the duty attaches to the Union importer whose annual volumes exceed the Annex I thresholds, not to the refiner abroad (Regulation (EU) 2017/821). For a future passport act the pattern will be the familiar one, that whoever places the product on the EU market answers for it. In both cases the practical work is contractual, since the data sits upstream. Settle the data clauses in the purchasing contract before you need them.
Do I need a GTIN?
No. A passport needs a unique identifier, not a particular scheme. Many maisons already carry an internal reference and a serial number, and those are enough. If you do have GTINs, the identifier in Transpareo becomes a GS1 Digital Link that retail systems resolve as well; without one the passport carries a unique Transpareo identifier and the QR code, engraved, printed or in the guarantee card, leads to it just the same.
Model passports or one per item?
In this industry, per item. A model passport can tell a buyer what a reference is; only an item passport can carry this object’s serial number, its manufacturing date, its service history and the authentication events on resale. Transpareo supports passports at model, batch and item level, and item level costs you nothing structurally - it is the same template with serial identifiers underneath.
Does a passport actually stop counterfeits?
Not by itself, and anyone claiming otherwise is selling something. A counterfeiter can print your QR code onto a copy. What a passport does is make the genuine record verifiable - each publication is signed, so a reader can check that this record was issued by you and not by someone else, and every earlier version stays retrievable. That turns authentication from a judgement about an object into a check against a record you control, which is what an auction house or a resale platform actually needs.
What does the ban on destroying unsold goods mean for us?
Since 19 July 2026 large companies may not destroy unsold consumer apparel, clothing accessories and footwear listed in Annex VII of the ESPR (Art. 25); medium-sized companies follow on 19 July 2030, and micro and small companies are exempt. Article 24 adds the duty to disclose the number and weight of unsold consumer products discarded per year. For an industry that has historically protected price positioning by destroying stock, this is the single most operative rule on this page, and it needs a data trail long before it needs a passport.
What about leather and the deforestation regulation?
Cattle is one of the seven commodities of Regulation (EU) 2023/1115, and its derived products reach hides and leather. The dates have moved repeatedly and the product list has been reopened, so treat any figure you read as provisional and check the Commission’s page linked above. The durable point for a leather house is unchanged - you will be asked where the hide came from, and the answer has to come from your tannery contracts rather than from a form filled in after the fact.
Can the passport carry the owner's name?
It can carry an ownership record, but think carefully before it carries a name. In Transpareo visibility is a property of every data field, so a service history can be public while the owner-facing part sits behind logged access. Personal data brings its own legal regime on top of product law, and the safer pattern is to keep the object’s history in the passport and the person’s identity in your client system, linked rather than merged. More on the mechanics in disclosure does not cost you the signature.
How long does a passport have to stay reachable?
No act sets a period for these categories yet, but the object outlives the question. A watch changes hands three times in forty years and the passport is worthless at the second sale if it has gone dark. So the number to insist on is not the legal minimum but what your provider does after a cancellation - with Transpareo, published passports stay reachable through a permanent address, and our provider checklist names the further questions worth asking any supplier.
Official documents
The legal sources to read for yourself: what each document is and when you need it.
- Regulation (EU) 2024/1781 (ESPR)The framework regulation for the product passport in every industry that gets one. Article 25 carries the ban on destroying unsold apparel, clothing accessories and footwear, Article 24 the disclosure duty, Article 13 the register. Read Article 25 first if you hold seasonal stock.
- Ecodesign and Energy Labelling Working Plan 2025-2030The Commission communication of 16 April 2025 that names the first product groups and their indicative years. This is where you check whether your category is in the queue at all, and where footwear's separate study is set out.
- Regulation (EU) 2017/821 on conflict mineralsThe supply-chain due-diligence rules for Union importers of tin, tantalum, tungsten and gold. Annex I holds the volume thresholds that decide whether you are in scope. Applicable since 1 January 2021, so this one is not a future duty.
- Commission page on the Conflict Minerals RegulationThe Commission's own overview, including the list of due-diligence schemes recognised as equivalent. Worth checking before you build a scheme of your own that the Commission already accepts.
- Implementing Regulation (EU) 2026/1778 on the DPP registryHow the central register works - identity verification, registration at model, batch or item level, versioning and retention. The item-level granularity is the part that matters in this industry.
- Commission page on the Deforestation RegulationThe current state of the EUDR, whose commodity list reaches cattle and its derived products. Dates and product scope have moved more than once, so read the page rather than a summary before you plan around leather.
- DPP page of the European CommissionThe official roadmap for the product passport with the state of the register and the delegated acts. The place where a new date for textiles or footwear appears first.
Further reading on our blog
Disclosure doesn't cost you the signature
Anyone shown protected fields usually has to trust the platform. We sign each field on its own, so those fields carry their own proof.
Trust that outlives the product: signatures and certificates in the DPP
A DPP has to stay verifiable for ten years; a platform rarely lasts that long. So trust attaches to the record, not to the provider.
From compliance document to marketing tool
Every QR scan is a consumer interaction. How companies use their DPPs as a lead-generation channel - without greenwashing.
Textile industry: closing the data gaps in the supply chain
From the fibre to the finished product: how fashion brands prepare for the ESPR obligations expected from 2029 by obliging the assembler to pass on the data of the weaver and the spinning mill.
Give every object its record
Start free and issue signed, item-level passports that authenticate in a scan and keep their value at resale.